NEDDC Local Plan Issues and Options Consultation on the Strategic Approach to the Location of Development and Refined Sites (March 2026)

This representation is submitted on behalf of Hallam Land Management Ltd in respect of the site ‘Land North of Eckington’ (45078). The defined site area includes site 45217 ‘Land at Back Lane’, which has also been submitted as separate site.

Density

For sites in Priority 1 or 2 locations, NEDDC have added a potential 20% increase in housing capacity. This is in response to consultation feedback which indicated widespread support for increasing densities in locations around larger settlements.

The LAA has considered the site, which is identified as 21.51ha to have a residential capacity of 409 and a policy-on residential capacity (with the 20% uplift) of 491 dwellings. The Issues and Options document identifies a potential for the delivery of 500 dwellings.

HLM acknowledge the desire to see density increase around larger settlements and are willing to discuss the appropriate density for this site with the LPA, taking into account any identified constraints or sensitivities.

Land Availability Assessment

The Land Availability Assessment (LAA), which is the evidence document which has informed the Refined Schedule of Sites put forward for consultation has identified this site as having a Suitability RAG rating of Red, and an overall conclusion of Red. Achievability and availability were given a RAG rating of Green.

We disagree with the Council’s conclusion on Red rating for suitability. It is noted that there are ecological constraints which the surround the site, but these could be mitigated through the design of any scheme. In terms of landscaping it is noted that the landscape officer concluded that the sites location is well contained by virtue of built development to the south and vegetation cover to the north. The highway authority consider an access could be delivered to the site and the details would be considered through a transport assessment. We explain below that the site should be classified as Grey Belt.

We therefore conclude that the suitability rating of Amber is more appropriate for this site, and that is it a suitable candidate for allocation in the draft Local Plan.

Green Belt

It is acknowledged that the site is located within the Green Belt, and the findings of the Green Belt review will be important in considering this site for development.

Paragraph 148 of the NPPF states that “Where it is necessary to release Green Belt land for development, plans should give priority to previously developed land, then consider grey belt which is not previously developed, and then other Green Belt locations. However, when drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should determine whether a site’s location is appropriate with particular reference to paragraphs 110 and 115 of this Framework”. Essentially this is a ‘sequential test’ approach.

We have considered whether the site is ‘Grey Belt’. Annex 2 of the NPPF defines the Grey Belt as “for the purposes of plan-making and decision-making, “grey belt” is defined as land in the Green Belt comprising previously development land and/or any other land that, in either case, does not strongly contribute to any of the purpose (a), (b) or (d) in paragraph 143. ‘Grey Belt’ excludes land where the application of the policies relating to the areas or assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development”.

Footnote 7 identifies that the policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites (and those sites listed in paragraph 194) and/or designated as Sites of Special Scientific Interest; Local Green Space, a National Landscape, a National Park (or within the Broads Authority) or defined as Heritage Coast; irreplaceable habitats; designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 75); and areas at risk of flooding or coastal change. None of these policies are considered relevant to this site, and as such do not restrict the classification of land as grey belt.

Purpose ‘a’ of the Green Belt is to ‘check the unrestricted sprawl of large built-up areas’, purpose ‘b’ is ‘to prevent neighbouring towns merging into one another’ and purpose ‘d’ is to ‘preserve the setting and special character of historic towns’.

In respect of purpose ‘a’ Planning Practice Guidance (PPG) states that a site is considered to contribute strongly to the purpose of restricting sprawl of an urban area if it is free of existing development and lacks physical features that could restrict and contain development. It is also likely to be both adjacent to a large built-up area and if developed, result in an incongruous pattern of development.

The site is largely free of existing development and lies next to the built-up area of Eckington. Existing woodland (High Bramley Wood and Ince Piece Wood) to the north provide physical features that can restrict and constrain development. The site cannot therefore be attributed to contribute strongly to purpose ‘a’.

In respect of purpose ‘b’ whilst this is a large site which on plan form would reduce the gap between Eckington and Mosborough, this would not result in the loss of visual separation due to the existing woodland to the north. As such the site does not contributes strongly to this purpose.

In respect of purpose d) Eckington is not a historic town. Whilst the site is within a conservation area, this is Moss Valley Conservation Area, which is a rural area and doesn’t include Eckington as a settlement. Whilst there is no conservation area appraisal for this area, as it does not include the settlement of Eckington it is not considered relevant to this test of Green Belt Policy. As such this purpose is not relevant to the consideration of the site.

As such for the purposes of assessment we conclude that development is being proposed on Grey Belt land.

The NPPF is clear that, when reviewing Green Belt boundaries, the need to promote sustainable patterns of development should determine whether a site’s location would be appropriate for the kind of development proposed. As set out in paragraph 110 and 115 of the NPPF it is clear that authorities should consider opportunities to maximise sustainable transport solutions.

As a Tier 1 settlement in NEDDC’s settlement hierarchy it is clear that this is a sustainable and appropriate location for growth. Sustainable transport connections, particularly for walking and cycling are proposed through the masterplan and provide a genuine opportunity for residents to travel into Eckington, where there are a good number of services and facilities, without the use of the car.

Overall, it is clear that this is an appropriate location and site for green belt release. Development will deliver much needed housing for the district, and the masterplan demonstrates how existing physical features can be enhanced to provide stronger boundaries to the edge of the Green Belt.

Ecology

Land to the rear of the site is identified as ancient semi-natural woodland and a Local Wildlife Site (LWS). Comments have been made that development of this site could have moderate to high impact on biodiversity. Future development of this site could mitigate for this, through features such as a landscape buffer or an off-set from the woodland, and replacement planting. This could also be delivered on parts of the site which are considered more sensitive (for example site 45217 ‘Land at Back Lane’

Whilst the ecologist comments on potential impacts on protected species are noted, this is not something which would immediately rule out a site from development and can be dealt with through the development management process on any future application.

At this point, whilst the surrounding site context is acknowledged, this does not provide an absolute constraint to the development of this site.

Archaeology

The recommendation for archaeological evaluation is noted. It is acknowledged that the site lies within an area of archaeological potential and if archaeological remains are located within the developable land, construction of the scheme will impact upon them. However, archaeological remains are not considered to be a restriction in terms of the development of the site and will be appropriately mitigated for as part of any future development proposal.

Heritage

Plumbley Colliery including Seldom Seen Engine House, a Scheduled Ancient Monument (list entry 1017746), is located north of the site within the woodland. The Engine House is the last remaining building from the Plumbley Collieries and provides evidence of the layout and operation of a 19th century coal mine. However, due to the intervening vegetation around the Engine House the links with the surrounding landscape and the value this provides to the understanding of setting is limited. As such this should prevent the development of this site.

The site is located on the southern edge of the Moss Valley Conservation Area. The conservation area is rural in character and doesn’t include the settlement of Eckington. There is no conservation area appraisal and so there is limited information available regarding its designation or the contributing factors to its significance. Due to the sites relationship with the settlement of Eckington and screening to the north, development is not considered to significantly affect the character and appearance of the conservation area and this should not be a constraint to development. Any masterplanning of the site would need to be informed by analysis of characteristics of the conservation area and would need to include suitable green infrastructure to mitigate any harm (if any) and provide a suitable buffer to the rural edge to the north.

Landscape

It is noted that the landscape officer concluded that the site’s location is well contained by virtue of built development to the south and vegetation cover to the north. Again, whilst the landscape sensitivities around the site are noted, this can be considered through the development management process on any future application. Landscape does not represent a constraint to prevent the development of the site.

Coal authority high risk area.

As per the heritage and archaeology sections the presence of former coal mine workings are acknowledged and can be mitigated for in any future development scheme.

Highways

The highway officer considers an access could be delivered to the site, the details would be considered through a transport assessment. It is clear that access could be achieved and we agree with the conclusions of the highway officer.

Conclusion

NEDDC has a challenging housing requirement of 12,100 homes over a 20 year period. To ensure that this figure is achieved, NEDDC will need to allocate land sufficient to meet this target and that will require a 10-15% buffer. Furthermore, the NPPF requires under Paragraph 149c that when defining Green Belt boundaries, plans should, where necessary, identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period.

There is no doubt that it is necessary for NEDDC to safeguard land. The extent of their housing challenge and the constraint that the Green Belt poses, means that a further Green Belt review will be required if safeguarded land is not considered.

The site should be classified as Grey Belt. Whilst there are heritage considerations which will require careful masterplanning and some technical constraints around the site, none of these issues are insurmountable, such that they should prevent the site being allocated for residential development. Eckington, as a main town, is a priority 1 location and this site represents an opportunity for a sensitive well-considered extension to the north of the town that would make a significant contribution to NEDDC’s housing requirement.

We support the approach to the location of development as this will focus development on the most sustainable settlements, where there is access to jobs and services and infrastructure capacity (or the ability to upgrade infrastructure without detriment to the viability of schemes). This also broadly aligns with the consultation responses provided on the Issues and Options consultation response.

The strategy identifies that development will involve maximising allocations in areas outside of the Green Belt, before considering sites within it; and then only where it can be shown to be necessary, i.e. exceptional circumstances can be demonstrated.

We agree that paragraph 145 of the National Planning Policy Framework (NPPF) confirms that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified. Exceptional circumstances include where an authority cannot meet its identified needs for homes, commercial or other development through other means. The Local Authority is required to demonstrate that it has examined all other reasonable options for meeting its identified need for development.

A large proportion of NEDDC is within the Green Belt, specifically in the northern part of the District. The north of the District contains three of the four largest settlements in NEDDC – Dronfield, Eckington and Killamarsh, which together with edges of Chesterfield/Sheffield and Strategic Sites comprise ‘Priority 1 Locations’. The presence of the Green Belt has severely restricted growth in these towns.

The NPPF, paragraph 149, is clear that plans should ensure consistency with the development plan’s strategy for meeting identified requirements for sustainable development, identify safeguarded land (not allocated for development at the present time) to meet longer-term development needs stretching well beyond the plan period, be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period and define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.

It is noted that NEDDC is undertaking a review of the Green Belt and this is welcomed. Paragraph 148 of the NPPF sets out that when considering Green Belt locations, plans should give priority to previously developed land, grey belt which is not previous developed and then other Green Belt locations. However, when reviewing boundaries, the need to promote sustainable patterns of development should determined whether a site’s location is appropriate, with particular reference to paragraphs 110 and 115 of the NPPF.

The standard methodology requires the delivery of 12,000 dwellings in the plan period. The Land Availability Assessment (“LAA”) has identified 565 sites which are considered to be deliverable or developable, with a potential for 16,447 dwellings. Of those 2 sites with planning permission can deliver 2,123 dwellings, deliverable sites (those rated green in the site assessment review) without planning permission can deliver 140 dwellings and developable sites (those rated amber in the site assessment review) can deliver 14,184 dwellings.

It is clear that release of Green Belt land will be necessary to meet the housing targets of the District, particularly in accordance with the justified approach to the proposed strategy for the location of development and the NPPF requirements to promote sustainable patterns of development. Utilising Green Belt land to deliver additional housing through carefully selected sites will not fundamentally undermine the purpose of the Green Belt and will allow for the delivery of much needed housing in the District.

The proposed settlement hierarchy identifies that Eckington has a score of 38+, with the other three Main Towns (and Level 1 settlements) of Dronfield, Clay Cross and Killamarsh all having a score of 40+. The next highest settlement score is Wingerworth at 31, which is a larger village (and a Level 2 settlement). The Settlement Hierarchy Topic Paper identifies that a settlement with a score of 32 or more, will be considered a main town. As set out in the Settlement Role and Function Study, which provides the evidence for the settlement hierarchy, given the clearly elevated sustainability performance of the four level 1 settlements and the role of their town centres, these settlements have not been assessed in any greater detail in the Study, but rather they be positioned at the top of the settlement hierarchy in the Local Plan. We support this approach. It is clear that the four main settlements in North East Derbyshire should be a clear focus for growth.

As part of the promotion of this site, HLM has commissioned technical work to support its allocation. The technical work has also informed a masterplan. Whilst the full details of those documents are not provided as part of the representations at this stage of consultation, summary details are set out below. HLM has entered the Local Plan Engagement Protocol with NEDDC.

Density

For sites in Priority 1 or 2 locations, NEDDC have added a potential 20% increase in housing capacity. This is in response to consultation feedback which indicated widespread support for increasing densities in locations around larger settlements.

The LAA has considered the site, which is identified as being 123.30ha to have a residential capacity of 1,745 and a policy-on residential capacity (with the 20% uplift) of 2,094 dwellings. The Issues and Options document identifies a potential for the delivery of 1,500-2,500 dwellings.

The masterplan work undertaken by HLM has proposed a density range of between 33-37 dwellings per ha which equates to circa between 1720 and 1930 dwelling. This level of development could be delivered whilst providing protection for more sensitive parts of the site and delivering significant areas of Green Infrastructure. HLM acknowledge the desire to see density increase around larger settlements and are willing to discuss and test the appropriate density for this site with the LPA, taking into account any identified constraints or sensitivities.

Green Belt

It is acknowledged that the site is located within the Green Belt, and the findings of the Green Belt Review will be important evidence to informing both the allocation of the site and the wider Local Plan.

Paragraph 148 of the NPPF states that “Where it is necessary to release Green Belt land for development, plans should give priority to previously developed land, then consider grey belt which is not previously developed, and then other Green Belt locations. However, when drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should determine whether a site’s location is appropriate with particular reference to paragraphs 110 and 115 of this Framework”. Essentially this is a ‘sequential test’ approach.

Without prejudice to the Green Belt Review that is being undertaken by the NEDDC and any comments that HLM may have on this assessment in due course, we have undertaken an evaluation as whether the site is ‘Grey Belt’.

Annex 2 of the NPPF defines the Grey Belt as “for the purposes of plan-making and decision-making, “grey belt” is defined as land in the Green Belt comprising previously development land and/or any other land that, in either case, does not strongly contribute to any of the purpose (a), (b) or (d) in paragraph 143. ‘Grey Belt’ excludes land where the application of the policies relating to the areas or assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development”.

Footnote 7 identifies that the policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites (and those sites listed in paragraph 194) and/or designated as Sites of Special Scientific Interest; Local Green Space, a National Landscape, a National Park (or within the Broads Authority) or defined as Heritage Coast; irreplaceable habitats; designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 75); and areas at risk of flooding or coastal change. None of these policies are considered relevant to this site, and as such do not restrict the classification of land as grey belt.

Purpose ‘a’ of the Green Belt is to ‘check the unrestricted sprawl of large built-up areas’, purpose ‘b’ is ‘to prevent neighbouring towns merging into one another’ and purpose d is to ‘preserve the setting and special character of historic towns’.

In respect of purpose a) Planning Practice Guidance (PPG) states that a site is considered to contribute strongly to the purpose of restricting sprawl of an urban area if it is free of existing development and lacks physical features that could restrict and contain development. It is also likely to be both adjacent to a large built-up area and if developed, result in an incongruous pattern of development.

The site is largely free of existing development, and lies next to the built-up area of Eckington. However, existing woodland at Foxstone Wood and Whinnybank Wood provide strong physical features that can restrict and constrain development. The masterplan as proposed seeks to strengthen the existing physical features and provide landscaping that will enhance and integrate existing features.

In respect of purpose b) whilst this is a large site which on plan form would reduce the gap between Eckington and Chesterfield, this would not result in the loss of visual separation. As such the site does not contributes strongly to this purpose.

In respect of purpose d) Eckington is not a historic town. Whilst it has a conservation area this is only applicable to a small area of the settlement. As such this purpose is not relevant to the consideration of the site.

As such, we conclude that the built form of development proposed in the masterplan is contained within ‘Grey Belt’ land, and that there are defensible boundaries for a revised Green Belt boundary which, in accordance with the NPPF can endure beyond the local plan period. As such for the purposes of assessment we consider that development is being proposed on Grey Belt land.

The NPPF is clear that, when reviewing Green Belt boundaries, the need to promote sustainable patterns of development should determine whether a site’s location would be appropriate for the kind of development proposed. As set out in paragraph 110 and 115 of the NPPF it is clear that authorities should consider opportunities to maximise sustainable transport solutions.

Even in the event the site is not determined to be Grey Belt we identify that Green Belt release will be required to ensure NEDDC meets its identified housing need as set out in the standard methodology. In the instance of this particular site it provides an opportunity to significantly contribute to that housing requirement which is in accordance with the justified approach to the proposed strategy for the location of development.

As a Tier 1 settlement in NEDDC’s settlement hierarchy it is clear that this is a sustainable and appropriate location for growth. Sustainable transport connections, particularly for walking and cycling are proposed through the masterplan and provide a genuine opportunity for residents to travel into Eckington, where there are a good number of services and facilities, without the use of the car.

Overall, it is clear that this is an appropriate location and site for Green Belt release. Further it is evident that NEDDC will require considerable Green Belt release to deliver its housing requirements. Masterplanning will be evolved throughout the plan preparation process to ensure a sensitive approach to the location of built development within the wider site.

Ecology

Early masterplanning has been informed by a Preliminary Ecological Appraisal, undertaken by Baker Consultants Limited. That assesses features of ecological value found to be present in the site and that information has been used to inform the development areas in the masterplan.

The proposed development site is agricultural in character, comprising arable and pasture fields with mature hedgerows, small, wooded areas and ponds.Current development proposals as set out in the masterplan, include the retention of high value features including woodland and ponds, and the creation of new woodland, grassland and scrub habitats.

Based on the extent of habitat retention and creation it is concluded that development will likely result in a net gain in biodiversity value of the site; subject to confirmation of habitat condition assessments following an optimal botanical survey.

Some habitats have been identified which are suitable to support a range of protected and notable species. Further survey work is recommended to determine the assemblage of species present on site and their usage of the site. Potential mitigation measures, depending upon the results of recommended further surveys, will be applied to ensure no significant ecological impacts result from the proposed development.

Archaeology

It is acknowledged that the site lies within an area of archaeological potential. Orion have been instructed to consider heritage issues in relation to the proposed allocation of this site, and those recommendations have fed into the masterplan.

Although the site is located within an area of post-medieval to modern industrial activity, a possible Roman road (MDR6150) crosses the site and archaeological investigations immediately to the north highlight the potential for late Iron Age and Roman activity, as well as early medieval industrial activity, to extend into the site.

There is a scheduled monument which comprises a tramway embankment (NHLE 1004601), c. 755m to the north-east of the site. There will be no direct impacts upon this, although there is the potential for there to be indirect impacts through a change to its setting.

Future archaeological investigations are therefore proposed. This comprises an Archaeological Desk Based Assessment (DBA), including a full search of the Historic Environment Record, to define the sites archaeological baseline and to further assess potential impacts to the Scheduled Monument of a tramway embankment and the completion of the geophysical survey to provide additional baseline information and to further support an application for development. Dependant on the results of the geophysical survey, archaeological evaluation trenching may be required in support of any future planning application.

Archaeological remains are not considered to be a restriction to the principle of development of the site and further work will inform more detailed masterplanning exercises as any scheme progresses.


Heritage

Heritage advised commissioned by HLM identifies the potential of impact from development on the Grade I listed Renishaw Hall, Grade II* Renishaw Hall registered park and garden and the Eckington and Renishaw Park conservation area. These are clearly all interlinked. The masterplan has therefore been designed to be sensitive to these features and to provide suitable mitigation.

A considerable green landscape buffer along the eastern site boundary is proposed as part of any masterplan. This would protect the area in closest proximity to the Grade II* Renishaw Hall registered park and garden and the conservation area. This green landscape buffer, along with the retained rural character of the south-east of the site, will ensure that there is no overbearing presence of development within the immediate setting of the relevant built heritage assets, and that the sense of the parkland’s rural environs is retained when travelling along Staveley Lane.

Where the proposed development would be visible from Staveley Lane and the westernmost extent of the Renishaw Hall parkland, this will be softened by the inclusion of planting along the eastern site boundary.

The technical note confirms that designed-in mitigation measures to any masterplan will serve to confine any potential levels of ‘less than substantial’ harm to the lower ranges. HLM is satisfied that the site can come forward without any significant harm to heritage assets.

Landscape

A review of the local landscape character and visual amenity has been undertaken by Influence, to establish a baseline and identify key receptors and associated sensitivities.

Overall, the Site is representative of the surrounding semi-rural and agricultural context and the local Landscape Character key characteristics of the Estate Farmlands LCT; with hedgerows enclosing medium size, semi -regular fields. Views out of the Site towards the south are generally long distance. The Site is managed as agricultural farmland and considered to be in good condition. Some positive perceptual aspects are noted where the sense of remoteness and tranquillity is experienced. The PRoW Bridleway NE 8 163/1 provides recreational value to the Site and is located within a secondary Area of Multiples Environmental Sensitivity. In consideration of these factors, the Site has a medium landscape value.

A series of viewpoints, representing different types of views and groups of receptors within both the immediate area and wider surroundings, have been identified to consider the visual impact of the proposed development.

Landscape considerations have and will continue to strongly influence the masterplan layout. The topography of the Site informs locations of SuDs and opportunities to create new habitats. Built development layout will be structured to retain existing hedgerows and field patterns, utilising the existing green infrastructure to create corridors through development for access and pedestrian/cycle links. This reflects the wider ‘woodland / treed’ character and intends to create a ‘layered’ effect, which assimilates the development into the landscape. The significant landscape buffer comprising strategy tree planting and open space along Staveley Road seeks to protect neighbouring Renishaw Hall Registered Park and Gardens and limit any harm from development. We would anticipate that this requirement would be part of any specific site allocation policy. The woodland character associated with the southern tip of the Site can be strengthened by strategic tree planting, which would also provide a buffer to the adjacent ancient woodland.

Any proposed layout will seek to incorporate vistas through the developable land parcels, capturing long distance views and retaining the visual connection with the wider landscape. Open space within the development affords more intimate and enclosed views, which will provide a network of different visual experiences. Proposed structural planting and landscape buffers provide opportunities to assimilate the development into the existing views towards the Site, reflecting wooded character and ‘nestled’ settlement setting.

Sustainable Transport

A Technical Note has been completed by Tetra Tech to consider transport and access in relation to the proposed site allocation. It demonstrates that a safe and suitable access for residential development is achievable, that the site is accessible by sustainable modes of travel, and that it’s proximity to local amenities and facilities to make them accessible by non-car modes. Further, the scheme will include facilities such as a local centre, a primary school and sports provision.

The proposed masterplan envisages a link road between Chesterfield Road and Staveley Lane. Early access assessment identifies a roundabout on Chesterfield Road, and a priority junction on Staveley Lane. This will be subject to further detailed assessment work in due course.

Flooding/Drainage

The vast majority of the site is Flood Zone 1, with a comparatively modest area of Flood Zone 2 and 3 on the eastern side of the site. This FZ 2/3 land will not be proposed for built development and will instead form part of the Green Infrastructure for the site. The site therefore should pass the sequential test and flooding is not a significant constraint to development. A drainage strategy for the site is emerging and this has again informed early masterplanning work.

Coal authority high risk area.

A Phase 1 Geo-environmental Desk Study and Coal Mining Risk Assessment has been undertaken by Rodgers Leask Limited (RLL). Whilst the majority of the site has been in agricultural use throughout the period covered by historical mapping, the site has been subject to extensive underground coal mining. Numerous records exist relating to surface working, shafts, spoil heaps and collieries on and surrounding the site. Site investigation work will be required to confirm further detail, and this will need to be taken into account in any future masterplan, however this does not provide a constraint to development of the land.

Conclusion

Overall, the technical work completed on the site has not identified any constraint to development and through the emerging masterplan, any impacts of development can be successfully mitigated. It is clear that this is a highly sustainable location where development is acceptable. Whilst the land is currently designated as Green Belt, release of this would meet the tests of exceptional circumstances to deliver housing need for the District and would not fundamentally undermine the purpose of the Green Belt.

The Site is available, suitable and achievable. HLM has significant experience in delivering high quality and successful sustainable urban extensions and this Site is capable of providing a substantial contribution to NEDDC’s challenging housing requirement. HLM SUPPORTS the allocation of this strategic site and is committed to ongoing discussions with NEDDC as part of the Local Plan Engagement Protocol.